AML Case Management: How Compliance Teams Investigate and Resolve Suspicious Activity

AML case management is the structured framework compliance teams use to investigate, document, and resolve suspicious financial activity. At a time when regulators are levying record fines for AML failures, and financial institutions face escalating alert volumes, effective case management has become a cornerstone of BSA/AML compliance. Without it, financial crime investigators risk missing key red flags, breaching reporting deadlines, or submitting weak filings that regulators question.

This guide explains the AML case management workflow, outlines best practices, and provides actionable steps for building an investigation process that is both efficient and regulator-ready.

What Is AML Case Management?

At its core, AML case management is more than just monitoring transactions—it is the end-to-end lifecycle for handling suspicious activity, from the first alert through to a Suspicious Activity Report (SAR).

A generic AML monitoring system may flag transactions, but without structured case management, institutions cannot ensure consistency, documentation, or regulatory compliance.

AML Case Management Defined

• Detect: Identify unusual behavior through an AML monitoring system.

• Investigate: Collect KYC/KYB data, review alerts, and analyze context.

• Resolve: Decide whether activity is suspicious or normal.

• Report: Escalate internally or file a SAR with regulators.

This framework ensures every suspicious activity undergoes a clear, auditable process, reducing operational risk and regulatory exposure.

The AML Case Management Workflow (Step-by-Step)

1. Transaction Monitoring & AML Alerts

The AML transaction monitoring process is the starting point. Financial institutions use automated systems to review customer activity and generate AML alerts whenever patterns suggest potential risk.

Examples of AML triggers include:

• Large cash deposits inconsistent with customer profile

• Wire transfers to or from high-risk jurisdictions

• Rapid in-and-out movement of funds across accounts

• Transactions just below regulatory thresholds

Strong systems also outline AML transaction monitoring procedures and provide analysts with a transaction monitoring process flow chart to guide consistent review steps. Without this automated detection, the money laundering investigation process would be unsustainably manual.

2. Alert Triage

Most AML alerts are false positives. Effective triage ensures resources are spent on credible risks.

Triage involves:

• Filtering out duplicate or incomplete alerts

• Applying risk scoring models to prioritize high-risk cases

• Reviewing customer profiles to align alerts with business nature

Institutions that skip triage face alert overload, overwhelming investigators and delaying legitimate case reviews.

3. Case Investigation

Once an alert is validated, the AML case investigation process begins. Investigators collect supporting information and analyze the customer’s overall activity.

Key investigation steps:

• Pull KYC/KYB data: identity documents, beneficial owners, business registration.

• Screen against sanctions lists (OFAC, UN, EU) and PEP databases.

• Check adverse media sources for reputational risk.

• Use data visualization to review transaction links and cross-account activity.

This structured money laundering investigation process ensures that compliance officers base decisions on verified evidence rather than assumptions.

4. Decision Making

After the investigation, compliance staff decide whether:

• The alert is a false positive and can be closed.

• The activity requires enhanced due diligence (EDD).

• A Suspicious Activity Report (SAR) must be filed.

Decision-making should follow a documented escalation protocol, ensuring consistency between different investigators.

5. Case Documentation

Every investigatory action must be documented to create a complete audit trail. Regulators expect institutions to retain “who, what, when, why” for each decision.

Documentation typically includes:

• Case summary and timeline

• Data sources used in the review

• Investigator notes and analysis

• Screenshots or exports from AML monitoring systems

• Final decision and rationale

This stage is critical for audit readiness and defending decisions in regulatory examinations.

6. Reporting

If suspicion remains, the institution must escalate to a SAR. Internal escalation goes to senior compliance or risk officers, while external reporting is to FinCEN or equivalent regulators.

SAR Filing & Compliance Timelines

SARs (Suspicious Activity Reports) are the most sensitive output of the AML case management process.

• Deadline: Institutions must file a SAR within 30 calendar days of detecting suspicious activity. If no suspect can be identified, the period may extend to 60 days.

• Confidentiality: SARs must remain confidential. Disclosing a SAR to the subject of the report is strictly prohibited.

• Retention: SAR documentation is retained for 5 years.

• Authority: Guidance comes from FinCEN AML Resources and the OCC BSA/AML Handbook.

Improving AML Case Management

An effective case management system is only as strong as its inputs, workflows, and oversight.

Data Quality & Integration

• Unify customer records, sanctions lists, payment data, and open-source intelligence.

• Eliminate siloed systems where investigators cannot access needed data.

Automation & Technology

• Use AI/ML models to reduce false positives and learn from investigator feedback.

• Employ workflow automation to speed case review and resolution.

• Many compliance teams now combine automation with investigator-verified solutions from BusinessScreen.comto balance speed with defensibility.

Refined Alert Triage

• Tune transaction thresholds to reduce unnecessary alerts.

• Use feedback loops to adjust detection models.

Investigation Consistency

• Implement standard templates for SAR narratives.

• Use peer review to validate investigator conclusions.

Audit Readiness

• Regular QA checks on historical cases.

• Built-in reporting dashboards to demonstrate regulator compliance.

Choosing an AML Case Management System

When selecting an AML case management system, institutions should ensure it provides:

• Workflow automation to reduce manual processing delays.

• API integrations with KYC, transaction monitoring, and sanctions databases.

• Comprehensive audit trail functionality.

• Role-based permissions to ensure data security.

• Built-in SAR drafting and submission tools.

• Scalability for growing alert volumes.

• Cloud deployment for flexibility or on-premise for higher control.

A strong system reduces operational risk while empowering investigators to focus on high-value investigative work.

Common Pitfalls to Avoid

• Alert overload: failing to triage, leaving teams overwhelmed.

• Data silos: fragmented information limiting investigator insight.

• Weak documentation: inability to justify case closures or SARs.

• Missed reporting deadlines: leading to regulatory penalties.

• Over-reliance on automation: failing to apply human judgment to complex cases.

FAQ: AML Case Management

What is AML case management workflow?
It is the structured sequence of steps to detect, investigate, document, and report suspicious activity.

What is an AML case investigation process?
It is the investigative stage where compliance officers review suspicious activity by analyzing transactions, KYC data, sanctions exposure, and adverse media.

What are AML alerts?
They are automated notifications generated by monitoring systems when unusual transactions or patterns are detected.

What is the AML transaction monitoring process?
It is the use of automated systems to review transactions in real time, flagging suspicious patterns for investigation.

What is the AML life cycle?
It refers to the end-to-end AML framework: detection, monitoring, case investigation, escalation, reporting, and continuous improvement.

What are AML use cases?
Examples include detecting structuring, monitoring high-risk jurisdictions, identifying shell companies, and flagging rapid wire transfers through correspondent accounts.

Conclusion & Call to Action

AML case management is central to compliance programs, enabling financial institutions to handle suspicious activity with efficiency, accuracy, and regulatory confidence. By combining workflow automation with investigator-verified oversight, compliance teams can reduce false positives, meet critical deadlines, and maintain strong audit trails.

By embedding strong case management into your AML strategy, you protect your institution, your customers, and the integrity of the financial system.

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